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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />81 <br />9' <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />minimize any potential harm or damage to persons, property, or the environment; <br />3. Evacuation plans and procedures, including immediate notice, for the <br />business site; <br />C. Violation of Health and Safety Code section 25504(c), failed to provide <br />training for all new employees and annual training, including refresher courses, for all employees in <br />safety procedures in the event of a release or threatened release of a hazardous material, including, <br />but not limited to, familiarity with the plans and procedures specified in Health and Safety Code <br />section 25504(b); <br />d. Violation of Health and Safety Code section 25505, failed to submit a <br />business plan for emergency response to a release or threatened release of hazardous material within <br />four (4) years prior to the filing of this complaint for 1010 INDUSTRIAL DRIVE, STOCKTON, <br />CALIFORNIA, to the San Joaquin County Office of Emergency Services. Further, it is alleged that <br />said violation was knowingly committed after reasonable notice; <br />e. Violation of Health and Safety Code section 25505(e)(2), failed to annually <br />submit a form, provided by the San Joaquin County Office of Emergency Services, that certifies that <br />the handler has included, and maintains as current, in the business plan, all other information <br />required by Health and Safety section 25504. <br />11. It is further alleged that defendants had reasonable notice of the violations contained <br />in paragraphs 10 - I Oe above, and that each day of violation thereafter was a knowing violation as <br />defined in Health and Safety Code section 25514. <br />THIRD CAUSE OF ACTION <br />VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br />(UNFAIR COMPETITION) <br />12. Paragraphs 1 through 11, above are incorporated herein by reference. Plaintiff is <br />informed and believes and based on such information and belief alleges that beginning at an exact <br />date that is unknown to plaintiff, but within four (4) years prior to the filing of this complaint (CCP <br />§338.1), defendants have engaged in acts of unlawful and/or unfair competition prohibited by <br />Business and Professions Code section 17200 et seq. by virtue of the acts described herein, each of <br />Complaint for Injunction, Civil Penalties and Other Relief <br />Page 5 <br />